Year End Investor Letter – Dec 21

This letter is not part of the fund prospectus or offering documentation of VT Holland Advisors Equity Fund. Opinions expressed below are only those of the manager and shared for the interest of readers only. Qualitative terms like ‘great’ and ‘compounding’ are used only to explain the managers investing approach. Readers are instructed to look at the full disclaimers and fund prospectus.

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Year End Investor Letter – December 2021


Dear Investors and Friends,

Performance*: Since last year end letter: Sept 2020-End Dec 2021 +53.0%

Performance*: For calendar year 2021 +12.2%

This letter covers the period since the VT Holland Advisors fund launched on 21st June 2021 until December 31st 2021. It also acts as the final report for the predecessor fund Farnam Street Capital for the period end-September 2020 – December 2021. From now on our year end is a December one.

In June this year our investor letter took the form of an owner’s manual. As we started a new chapter with a UCITS fund platform I believed it was a good way to communicate how I thought about a variety of issues that did not just relate to the performance of the fund or how I go about investing your/our money. If you have not read that letter, maybe take a look. This letter returns to a more normal format. Initially I will discuss my investing approach and the market backdrop we are experiencing. Later then looking at examples of companies we own and the rationale for why.

Investment approach

In June when trying to explain my investment approach I penned the following. I see little reason to change a word:

The rationale I use in investing remains steadfast. I try to buy the shares of businesses I think are set to offer us attractive long term compounding potential.

Usually, such businesses make good or great returns on capital and have strong competitive positions. Unusually, they may be hated (or disliked at least) by Mr Market at the time I make our purchase. This last point is perhaps what distinguishes our fund from others that might label themselves as having a ‘franchise’ approach. I share many of the same philosophies as ‘franchise’ investors, but instead consider myself as having a ‘compounding’ approach. The difference is perhaps subtle and one I hope that Mr Munger and many readers will understand.

Admiring great companies, I think is a perfectly reasonable activity. However, over time I think superior returns will be made by investing in such companies when they are priced either for failure, or at least for a fade in their growth, when in fact the business model is actually primed for success. The last key ingredient that goes into our not-so-secret mix is the Owner Manager.

Almost always I am looking to invest alongside a CEO/founder/family who are aligned with us. They will have likely demonstrated past powerful compounding by managing and growing the business successfully for a long period through a variety of environments.

An evolving and adaptive process

Whist the paragraphs above continue to capture the essence of what I am trying to do when investing our collective monies all organisms and organisations on this planet that prosper do so by constantly evolving. We must do likewise. It is perhaps more accurate to talk of my investment approach as ‘evolving’ and ‘adapting’ for each perhaps explains a subtle difference. The ‘evolution’ is by way of self-improvement. If up to now you thought you were invested alongside the perfect fund manager, I have news for you..! Investing is a highly competitive and sometimes complex industry where there is always room to learn and improves one’s approach. Each year I learn volumes from mistakes made and missed opportunities. Whilst the core tenets of my approach are not going to change as I believe they are built on good foundations there is much I can and should be willing to learn.

The ‘adaptation’ I speak of could be looked at differently. This being the need to adapt the investment approach we are taking to best match the opportunity set that confronts us today. Perhaps this is better explained by way of some examples:

Companies like Coca Cola or Fevertree are great businesses. They own loved brands, grow, but require little capital to do so. As such they are businesses, I am happy to state I would like to be invested in. However, the ease of understanding their good business models by other investors results in their price often reflecting their quality and growth prospects. Sometimes the price more than reflects these traits.

“It’s getting very difficult because we have a vast increase in the intellectual horsepower that’s trying to get rich by owning securities. They’ve bid the good businesses up and up and up. In America, at least, almost every great business is selling 35 times earnings or more.” “it is fine holding these great companies but their best value creation is behind them.”

“…There’s no great company that can’t be turned into a bad investment, just by raising the price.” Charlie Munger, November 2021

Today’s investing markets are interesting (when were they not?). A multi-year love fair with ‘great businesses’ or ‘franchises’ has occurred. This process has been so successful and reinforcing that a mantra of needing to own and pay up for these ‘great’ companies has become widely accepted. To many investors today all other companies are seen as ‘also rans.’ In today’s stock market if you want mispricing’s you will likely only find them in the ‘also rans.’ This area might include: Non-ESG qualifying investments, deep cyclicals, higher capital intensity companies or those with complex/opaque structures or mistrusted managers. This list is far from exhaustive. Conducting a company-by-company search for interesting investments in this area amongst tens of thousands of companies would take an age. Also, if doing so, great care is needed for clearly whilst the Coca Cola’s and Fevetree’s of the world are wonderful businesses, the pool we are now fishing in contain many (un)wonderful ones!

“I used to search for cheap companies. I was unlucky enough to find a few!” Warren Buffett

Any readers that have listened to one of my conference presentations will have heard me quote Joel Greenblatt on the importance of knowing what you are looking for in investment before you start your search. #matchinthedynamitefactory

The difference between others using a ‘franchise’ approach and our ‘compounding’ one is maybe just of pragmatism as to where an opportunity might come from. Whilst we admire many branded high return businesses if the price they are offered to us brings little margin of safety we are inclined to look elsewhere. In doing so however we are mindful of the mistakes of our investing past (deep cyclicals and uncertain management turnarounds). Our ears prick up therefore when in the ‘also rans’ we find neglected companies that also meet our criteria i.e. they are owner managed with proven long term compounding ability.

Business models and mental models

More often than not a new investment may present itself by an opportunity ‘looking a lot like something we have seen before’. This will either be due to your manager taking a different view as to the prevailing one that may be driving a particular stock or sector (a mental model). Alternatively, by making a different assessment as to the power of the model a company is deploying (business model).

A current example of using a mental model, where I believe there is a flaw in other investors thinking toward a company or sector, is the ‘recency bias’ that hit some travel and leisure companies hard during Covid-19. Cash burn, survival and equity dilution must be considered for businesses in this area. However, some share prices discounted traveller caution many years into the future. Something I thought very unlikely.

The very best global businesses are well understood and mostly priced correctly. Finding value in them requires an investor to be thinking differently from the majority of others in the market. Opportunities can occur when a negative view of even a well know company becomes ingrained and widespread. Buffett’s investment in Coke and American Express were good examples. We are hoping that the fund’s recent investments in Facebook, Alibaba and Boohoo are examples too. Time will tell.

Such opportunities are what we might call ‘growth stocks priced to fade’. In truth they are rare to find. As a result, the majority of our ideas more often come from the recognition of a successful business model that we know well but find in a new sector or geography. Whilst we have many such models in our heads our favourite by far is the Scale Economy Shared model.

I had been analysing and admiring the business model of companies like Greggs, Ryanair and JDW for many years. I used to refer to them as flywheel businesses or EDLP (everyday low prices) ones. However, having read the excellent Nomad letters by Nick Sleep and Qais Zakaria a year or two back I have since cloned their use of the “Scale Economy Shared” label. The reason being that it perfectly captures what these companies try to do i.e. share the benefits of the scale economies they get from increased size with their customers:

“In contrast, a business with scale economies shared passes on the benefits of its growth to its consumers. This aligns incentives rather wonderfully, and it turns out to be somewhat difficult for a regulator (or even a set of consumers) to crack down on a business that so consistently passes on its profits to its customers.” Source: Nomad Investment Letters/IGY Foundation

Today c.35-40% the fund assets are invested in businesses that pursue this scale economics shared model. What is particularly interesting to us about companies with such a model are two aspects:

  1. Their long-term growth tends to beat the fade anticipated by analysts
  2. Quite often, (but not always) these companies’ shares can be mispriced

Beating the fade

Due to these companies’ relentless and consistent investment in price (and service) they are building up a valuable asset that is invisible to investors. This being the loyalty of their current and future customer base. Why do we say ‘future’? Because these are the customers that will turn up when today’s ones tell them what a great deal they are getting. Despite such an asset being hugely powerful in its ability to drive future sales and cashflow growth for years to come, it is unseeable and unknowable. Indeed, an analyst trying to put this on his spreadsheets would be roundly laughed at. The real-life impact of such an asset however is that such companies are consistently able to grow at much faster rates for much longer than is expected of them as a result. After all, as Mr Sleep alluded to in the quote above, rarely is there any regulatory intervention in such businesses as consumers are seeing pricing being reduced not raised. Additionally low prices and good service levels tend to detract rather than attract new competitors.

As an aside for those that see this as a new-age business model we recommend the book Titan by Ron Chernow. It is the remarkable story of John D Rockefeller’s life. He built an enormous US oil empire (Standard Oil) during c.1870-1910 by taking over many competitor oil fields. The secret sauce to his success I would suggest however was his attitude to pricing. These he tried to keep low (not high) despite the near monopoly position he was often achieving.


Having just articulated that these Scale Economy Shared businesses grow for longer and more steadily than many others, why would they not surely be priced higher by the stock market? We think they should, but oftentimes Mr Market disagrees with us. The reason for this often comes down to timescales or what Charlie Munger sees as an understanding of “deferred gratification” These businesses are primed for long term growth, but often that comes as a result of being wired to endure some form of short-term pain.

An example can be seen in one of our favourite UK investments – J D Wetherspoon. The pricing deferential between it and all other UK pubs is large and growing. As a result, when cost inflation (in wages and utility) occurred JDW could easily have raised its prices as all other pubs chains did to offset these costs and protect margins. Its multi-year reluctance to do so has resulted in profit margins that are half many of its peers and have fallen now for a number years. During this period however its reputation with customers as the out-and-out price leader in this sector has never been stronger. Thus its brand has a future ability to grow and has been reinforced. Having the stomach and determination to pursue such a strategy when all around you (sometimes you author included!) are telling you to raise prices a little requires an enormous amount of discipline, determination and belief in the power of your long-term business model. These traits in the face of lower margins than peers are not always seen as attractive by the short-term weather vane that we call’ Mr Market.’

The economic and investing backdrop

“The purpose of astrology is to make economics look respectable” Ezra Solomon

Each and every year the economic and stock market backdrop will have an effect (sometimes a large one) on the investment performance result we record. As a consequence of this undeniable link many investors spend a great deal of time trying to predict the economic future so as to try and aid their chances of performing better. Whilst there seems logic in this approach, I see it as tantamount to tea leaf reading. Our focus is on trying to develop an all-weather investment approach that is adapted a little to the environment we find ourselves in. Long suffering readers of these letters will have heard me before describe the macro environment akin to the wing mirrors in my car. Whilst I spend the vast majority of my time looking out of the front windscreen in my search for great companies that will offer wonderful compounding opportunities, I do glance in my wing mirrors occasionally. This is mostly just to check a tornado isn’t about to hit our car/portfolio from behind. Indeed, it was exactly this reflection that made us take a more cautious view in early 2020, just before Covid hit Europe.

It is important on this point to not be disingenuous. Of course I am aware of the many macro issues that surround investors today and their ever-changing probabilities. However, readers should know that I spend (a lot) less time trying to forecast these issues than many other managers.

Our wing mirrors during 2021 clearly showed signs of potential higher future interest rate and inflation. On both issues there is a great deal of debate from many in each entrenched camp. A few years ago our contrarianism saw us own banks for just such a recovery/normalisation in their returns that would result from higher rates. Today I feel somewhat different. It is not that such companies will/will not benefit from such a change, but instead what is the opportunity cost of me owning them while I wait. Additionally what is my edge in understating these companies over other investors? In truth it is likely ‘none’. Today we are super focused on finding great compounding opportunities that are run by exceptional owner managers, looking far and wide to find them. Furthermore, we are finding lots of them and are excited by the compounding prospects they might bring to the fund. So instead of owning companies that may benefit from our macro predications (if we were correct) instead we watch out for free options from macro tailwinds. An example is our ownership of Schwab. Schwab is a perfect example of a powerful scale economy shared business that is still heavily influenced by its founder. We use the next label carefully, but we believe it is the ‘Amazon of financial services’. Its growth is not set to fade as many of its analysts have regularly projected due to the wonderful value it offers its customers. Schwab however is also a huge beneficiary of higher interest rates due to the enormous amount of sticky customer assets that sits on its balance sheet. This free option was not lost on us when buying into Schwab in the past few years. The power and resulting growth of its business model was its main attraction. But that its profits could be materially higher in a normalised interest rate world vastly improved its margin of safety/attractiveness at the time of purchase. We will openly admit that we would one like to own more Schwab shares than we do. We also have another company in the portfolio with the identical interest rate exposure to Schwab.

Frasers and Biglari Holdings – Method or madness…?

Any that have followed our research in recent years will know that we have been fans of Sports Direct (now called Frasers) since its fall from grace in 2015. Often when admitting our attraction to and ownership of such a company we have been looked at by many a fellow investor strangely. It is the look you might give to someone whom you are thinking of crossing the road to avoid! Mike Ashley’s drinking ability, football club ownership and general demeaner seem to have overpowered investors and commentators alike we note, irrespective of their level of experience.

Mike Ashley is undoubtedly a maverick. He is also culturally about as far away from the London financial establishment as it is possible to be. However, our assessment of his business abilities is that he perhaps has one of the best understandings of market power and competitive positioning of anyone we have met. We have attended numerus investor meetings with this company over the last 5 years and a few of them were press/ESG/Union circuses. During one such circus Mike was asked what his customers would think of the company’s future elevated store offering (i.e. less discounting/more full price). Mike’s six word answer we thought was telling. Its importance was also missed on the audience:

“Where else are they going to go?” Mike Ashley

Earlier we referenced our use of repeatable mental and business models. On hearing the above phrase, one popped into our heads. It was of Buffett describing the permanently improved pricing power that resulted when a local newspaper market consolidated from three players to two. Ashley’s decades of discounting saw its relationship with Nike come to head c.5 years ago. His then acceptance of a new way of selling sportwear’s that resulted (i.e. more of it at full prices) was clearly influenced by Nike’s demands. However crucially the competitive environment he had created prior to this point by killing off numerous competitors was a critical factor too. Consumers had nowhere else to go. Today we surmise that Frasers relationship with Nike has never been better. In the coming years the company looks set to achieve high gross margin sales via both its Sports Direct and Flannel facias overlaying these on a still super-efficient distribution network. The resulting impact of profitability will surprise many we think. The recovery in the company’s share we believe has only just started.

Enter stage left Sardar Biglari

If you think Mike Ashley has a strained relationship with investors you should meet Sardar Biglari. There is no communication with investors outside quarterly SEC releases, the AGM and the annual letter. Even at the AGM Sardar is often prickly when answering a question, he might not see as suitably researched. There have been proxy fights in the past and all manner of unpleasant things written about Mr Biglari from US commentators. (The annual letter by the way is both candid and very open about the company, its businesses and mistakes Sardar may have made).

All of this is Mike Ashley-esq in the disconnect between superficial market commentary and proper business analysis. This interests us because we believe Mr Biglari to be a talented businessman, investor and capital allocator. He is an outright owner of whole businesses inside Biglari holdings (the quoted share that we are invested in), but also an investor in publicly quoted shares. We observe that the purchases he has made over the last c.15years have often had areas of hidden value that others miss. Examples would be oil reserves that produce far more cash than profits due an ongoing depletion charge, but he bought the business out of bankruptcy. Also, the never mentioned, heavy freehold property backing that came with his purchase of restaurant chain Steak and Shake. Unusually Mr Biglari looks to have multiple skill sets in both asset heavy and asset light industries. He also has a great understanding of ‘float’, having purchased two specialist insurance businesses with very impressive combined ratios. As a result of our multi-year study of Sardar Biglari and the company he holds a c.60-65% interest in we surmise that he has the skill to be able to grow investor capital (his and ours) at a high rate for many years into the future.

Only the half of it

In the Appendix of this letter, you will see a summary of the balance sheet on Biglari Holdings as at end September 2021. We hope that even to the untrained eye a few points stand out:

  • That the group has shareholder equity of c.$599m
  • That there is no debt in the company so the vast bulk of this $599m comes from either ‘Property and equipment’ or ‘Investment partnerships’
  • There is a large negative number ($396m) attached to ‘Treasury stock, at cost’

A glance at your Bloomberg, Capital IQ or Google Finance source will then tell you that Biglari Holdings has market capitalisation of c.$420m (Share in issue x price) at 17th January 2022 prices.

Mr Biglari however is shrewd and, like Mike Ashley, is a man to watch what he does more than what he says (which is not a lot). Biglari Holdings over the last 5y+ years has bought back an enormous amount of its own stock and this stock sits in two funds inside the company.

The company however has 66.1% and 92.9%% ownership of these funds (as at 30th June 2021). As a result, the effective shares in issue for this company on a look through basis we believe is almost half the stated level (i.e. the one Mr Market is using).

The upshot of all this is that we have a company run by an owner manager who we think will grow and allocate its capital very well many years (even decades) into the future. But whose shares are offered to us at maybe a third of their value today. (NB: we think the company is worth more than the $599m figure considering the earnings potential of different parts of the business).

In modern efficient stock markets how is such a mispricing possible? Partly by the fact that there is no analyst coverage of this company. But also, we think by the confusion of emotion and analysis. Like Frasers in the UK, so many investors have decided to hate/distrust/dismiss Sardar Biglari they have either stopped thinking clearly or more likely just refuse to look at its accounts.

To misquote Buffett’s view on bear market pricing “It is not that we like uncommunicative, unpredictable Owner managers that have a sometimes-strained relationship with investors, but we like the prices that they bring.”

In closing

The fund is now a daily dealing UK UCITS fund with links to its pricing shown on the Holland Advisors and Valu-Trac websites. It is available to invest via most UK wealth managers and many investment platforms. Disclosure of our major holdings and the geographic split of how the fund is invested are show on the monthly fact sheet.

Thank you for your interest and for investing alongside me. As I have stated many times before I cannot predict the return the fund will make in the future. All I can do is work hard to try to ensure we own the best selection of investments that give us the greatest chance of compounding our capital at a good rate many years into the future. Whilst keep an eye on downside risks.

With kind regards

Andrew Hollingworth, Fund Manager

17th January 2022

The information in this document is based upon the opinions of Holland Advisors London Limited and should not be viewed as indicating any guarantee of returns from any of the firm’s investments or services. The document is not an offer or recommendation in a jurisdiction in which such an offer is not authorised or to any person to whom it is unlawful to make such an offer. The information in this Report has no regard to the specific investment objectives, financial situation or particular needs of any specific recipient and is published solely for informational purposes and is not to be construed as a solicitation or an offer to buy or sell any securities or related financial instruments. In the absence of detailed information about you, your circumstances or your investment portfolio, the information does not in any way constitute investment advice. Potential investors should refer to the relevant Prospectus and Key Information Investor Document for full information. If you have any doubt about any of the information presented, you should obtain financial advice. Past performance is not necessarily a guide to future performance, the value of an investments and any income from them can go down as well as up and can fluctuate in response to changes in currency exchange rates, your capital is at risk and you may not get back the original amount invested. Any opinions expressed in this Report are subject to change without notice. Portfolio holdings are subject to change and the information contained in this document regarding specific securities should not be construed as a recommendation or offer to buy or sell any securities referred to. The information provided is “as is” without any express or implied warranty of any kind including warranties of merchantability, non-infringement of intellectual property, or fitness for any purpose. Because some jurisdictions prohibit the exclusion or limitation of liability for consequential or incidental damages, the above limitation may not apply to you. Users are therefore warned not to rely exclusively on the comments or conclusions within the Report but to carry out their own due diligence before making their own decisions. Authorised and regulated by the Financial Conduct Authority (UK), registration number 538932. All rights reserved. No part of this Report may be reproduced or distributed in any manner without the written permission of Holland Advisors London Limited. Investment Manager: Holland Advisors London Limited (registered number 538932), registered office 7 York Road, Woking, Surrey, GU22 7XH.

Appendix: Extract from Biglari Holding 10Q September 2021

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The information provided does not constitute advice. Holland Advisors believes that the sources of the information in this website are reliable. However it cannot and does not guarantee, either expressly or implicitly, and accepts no liability for, the accuracy, validity, timeliness or completeness of any information or data (whether prepared by it or by any third party) for any particular purpose or use or that the information or data will be free from error. Holland Advisors does not undertake any responsibility for any reliance which is placed by any person on any statements or opinions which are expressed herein. Neither Holland Advisors nor any of its directors, officers or employees will be liable or have any responsibility of any kind for any loss or damage that any person may incur resulting from the use of this information. This does not exclude or restrict any duty of liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom. All Information may be changed or amended without prior notice although Holland Advisors does not undertake to update this site regularly.

Marketing Communications
Documents on this site do not constitute investment research as they have not been prepared in accordance with UK legal requirements designed to promote the independence of investment research. Therefore, even if they contain research recommendations they should be treated as marketing communications and as such will be fair, clear and not misleading in line with Financial Conduct Authority rules. These communications are not personal recommendations to you and any opinions cited are subject to change without notice. Holland Advisors takes all reasonable care to ensure that the information on this site is accurate and complete; however no warranty, representation, or undertaking is given that it is free from inaccuracies or omissions. Documents on this site are based on, and contain, current public information, data, opinions, estimates and projections obtained from sources we believe to be reliable. Past performance is not necessarily a guide to future performance. The content of these documents may have been disclosed to the issuer(s) prior to dissemination in order to verify their factual accuracy.

Investments in general involve some degree of risk, therefore Prospective Investors should be aware that the value of any investment may rise and fall and you may get back less than you invested. Value and income may be adversely affected by exchange rates, interest rates and other factors. The investments discussed on this website may not be eligible for sale in some states or countries and may not be suitable for all investors. If you are unsure about the suitability of an investment given your financial objectives, resources and risk appetite, please contact your financial advisor before taking any further action.

Holland Advisors and/or its officers, directors and employees may have or take positions in securities, funds or derivatives mentioned on this site (or in any related investment) and may from time to time dispose of any such securities (or instrument). Holland Advisors manages these potential conflicts of interest internally via its compliance procedures.

Fund Information
Parts of this site may refer to Funds managed or advised by Holland Advisors. These are not solicitations to invest and any potential investors should refer to the “Our Funds” section of the website in order to learn more about these Funds and find out how and where to obtain the relevant full legal documentation.

Linked Websites
This site may be linked to third party websites or contain information provided by third parties. Holland Advisors does not make any representation as to the accuracy or completeness of such websites or information, has not and will not review or update such websites or information, and cautions browsers that any use made of such websites or information is at their own risk. Holland Advisors does not accept any liability arising out of the information contained on any linked website or Information provided by a third party and the use of such sites and information is at your own risk. This does not exclude or restrict any duty or liability that Holland Advisors has to its customers under the regulatory system in the United Kingdom.

You agree to indemnify and defend Holland Advisors, its affiliates and licensors, and the officers, directors, employees, and agents of Holland Advisors and its affiliates and licensors, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use of this website and the Information.

Use of Cookies
If you agree to these terms and conditions a “cookie” might be placed on your computer. A cookie is a packet of information that does not identify individual users of a website, but allows the collection of website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site). We can use this information for statistical purposes, which allows us to analyse and improve our website. The cookie will expire automatically after 6 months or you can manually remove cookies in your browser settings.

Copyright, Trademarks and Other Rights
Copyright, trademarks, database rights, patents and all similar rights in this site and the information contained in it are owned by Holland Advisors or relevant third party providers. You may use the Information and reproduce it in hard copy for your personal reference only. The information contained herein and any supplemental documentation provided is confidential and should not be copied, reproduced or redistributed without the prior consent of Holland Advisors.

Governing Law
You agree that your use of this site and any dispute arising from this use is subject to English law and you submit to the jurisdiction of the Courts of England & Wales.

Privacy Notice

This is the privacy notice of Holland Advisors London Ltd our company number is 07431314. Our registered office is at 7 York Road, Woking, Surrey, GU22 7XH.



This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected through our website

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.


Data Protection Officer

We have appointed a data protection officer (‘DPO’) who is responsible for ensuring that our privacy policy is followed. If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact our DPO, Claire Brunt at


Personal data we process

1. How we obtain personal data

The information we process about you includes information:

  • you have directly provided to us
  • that we gather from third party databases and service providers
  • as a result of monitoring how you use our website or our services

2. Types of personal data we collect directly

When you use our website, you may provide personal data by submission of data by our Sign Up or Contact Us forms. This can be categorised into the following groups:

  • personal identifiers, such as your first and last names
  • contact information, such as your email address and your telephone number for communication
  • records of communication between us including messages sent through our website, email messages and telephone conversations
  • marketing preferences that tell us what types of marketing you would like to receive

3. Types of personal data we collect from your use of our services

By using our website and our services, we process:

  • technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
  • usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
  • your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.

4. Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

5. The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

6. Information we process with your consent

Through certain actions when there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, you provide your consent to us to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us

7. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

  • improving our services
  • record-keeping for the proper and necessary administration of our business
  • responding to unsolicited communication from you to which we believe you would expect a response
  • preventing fraudulent use of our services
  • exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
  • insuring against or obtaining professional advice that is required to manage business risk
  • protecting your interests where we believe we have a duty to do so


How and when we process your personal data

8. Your personal data is not shared

We do not share or disclose to a third party, any information collected through our website.


Use of information we collect through automated systems

9. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

10. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.


Other matters

11. Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at

12. Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business. We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

13. Complaining

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.

When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.

14. Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us to provide you with the services you have requested.

15. Compliance with the law

Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

16. Review of this privacy policy

We shall update this privacy notice from time to time as necessary.